Federal Communications Commission

Office of Engineering & Technology

__________________________________

Evaluating Compliance with FCC

Guidelines for Human Exposure to
Radiofrequency Electromagnetic Fields

Additional Information for Radio and

Television Broadcast Stations

Supplement A
(Edition 97-01)
to
OET Bulletin 65 (Edition 97-01)
 Evaluating Compliance with FCC
Guidelines for Human Exposure
to Radiofrequency Electromagnetic Fields

Additional Information for Radio and

Television Broadcast Stations

SUPPLEMENT A
Edition 97-01
to
OET BULLETIN 65
Edition 97-01

August 1997

AUTHORS
Robert F. Cleveland, Jr.
David M. Sylvar
Jerry L. Ulcek

Standards Development Branch

Allocations and Standards Division
Office of Engineering and Technology
Federal Communications Commission
Washington, D.C. 20554
 ACKNOWLEDGEMENTS

The following individuals and organizations from outside the FCC reviewed an early draft of
Bulletin 65, including the material in this supplement. Their valuable comments and
suggestions greatly enhanced the accuracy and usefulness of this document, and their
assistance is gratefully acknowledged.

Joseph A. Amato, Maxwell RF Radiation Safety, Ltd.

Edward Aslan, Lockheed Martin Microwave (Narda)
Ameritech Mobile Communications, Inc.
Dr. Tadeusz M. Babij, Florida International University
Dr. Quirano Balzano, Motorola
David Baron, P.E., Holaday Industries, Inc.
Howard I. Bassen, U.S. Food and Drug Administration
Clarence M. Beverage, Communications Technologies, Inc.
Dr. Donald J. Bowen, AT&T Laboratories
Cellular Telecommunications Industry Association
Dr. C.K. Chou, City of Hope National Medical Center
Jules Cohen, P.E., Consulting Engineer
Dr. David L. Conover, National Institute for Occupational Safety & Health
Cohen, Dippell and Everist, P.C.
Robert D. Culver, Lohnes and Culver
Fred J. Dietrich, Ph.D., Globalstar
Electromagnetic Energy Association
Professor Om P. Gandhi, University of Utah
Robert Gonsett, Communications General Corp.
Hammett & Edison, Inc.
Norbert Hankin, U.S. Environmental Protection Agency
James B. Hatfield, Hatfield & Dawson
Robert Johnson
Dr. John A. Leonowich
Dr. W. Gregory Lotz, National Institute for Occupational Safety & Health
Frederick O. Maia, National Volunteer Examiners (Amateur Radio Service)
Ed Mantiply, U.S. Environmental Protection Agency
Robert Moore
Dr. Daniel Murray, Okanagan University College
Dr. John M. Osepchuk, Full Spectrum Consulting
Professor Wayne Overbeck, California State University, Fullerton
Personal Communications Industry Association
Ronald C. Petersen, Lucent Technologies
David B. Popkin
Kazimierz Siwiak, P.E.
Richard A. Tell, Richard Tell Associates, Inc.
Rory Van Tuyl, Hewlett-Packard Laboratories
Louis A. Williams, Jr., Louis A. Williams, Jr. and Associates

Contributions from the following FCC staff members are also acknowledged:
Kwok Chan, Errol Chang, William Cross, Richard Engelman, Bruce Franca and Jay Jackson
 TABLE OF CONTENTS

Page

INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii

SECTION 1: AM Radio Broadcast Stations . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 - 10

TABLES 1-4: Predicted distances for compliance with FCC limits . . . . . . . . 4 - 5

FIGURES 1-4: MININEC AM Model for 1 kW (Field Strength v. Distance) . 6 - 9
FIGURE 5: Estimated power levels to comply with occupational/controlled
limits (on tower exposure only) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

SECTION 2: FM Radio Broadcast Stations . . . . . . . . . . . . . . . . . . . . . . . . . . 11 - 28

TABLES 5-6: Minimum height required for single FM antenna compliance 17 - 18

FIGURES 6-15: Predicted "worst case" power density @2 m above ground)s 19 - 28

SECTION 3: Television Broadcast Stations . . . . . . . . . . . . . . . . . . . . . . . . . . 29 - 38

TABLES 7-8: Distances for single VHF-TV antenna compliance . . . . . . . 33 - 34

TABLES 9-12: Distances for single UHF-TV antenna compliance . . . . . . . 35 - 38

i
 INTRODUCTION

This supplement is designed to be used in connection with the FCC’s

OET Bulletin 65, Version 97-01. The information in this supplement
provides additional detailed information that can be used for evaluating
compliance of radio and television broadcast stations with FCC guidelines
for exposure to radiofrequency electromagnetic fields. However, users of
this supplement should also consult Bulletin 65 for complete information on
FCC policies, guidelines, compliance-related issues and methods for
achieving compliance.

NOTE: The first edition of Bulletin 65 was issued as OST Bulletin No. 65 in October
1985. This supplement contains broadcast-related information and data that have been
revised from that which was included in the original bulletin.

Mention of commercial products does not constitute endorsement by the Federal Communications Commission
or by the authors.

ii
 SECTION 1
AM Radio Broadcast Stations

In determining compliance with limits for Maximum Permissible Exposure (MPE) for
AM radio broadcast stations, it is normally most important to determine electric and magnetic
field strength at distances relatively close to transmitting antennas. Fields from these
monopole antennas decrease relatively rapidly with distance, and MPE limits for AM radio
frequencies are not as restrictive as those for other frequencies, such as those used for FM
radio. Therefore, even for the highest powered stations, MPE limits for AM radio
transmissions would normally only be exceeded relatively close to antennas. Compliance
with the FCC’s guidelines for AM stations typically will involve assessment of exposure
potential of persons working or occupying areas in the close-in vicinity of transmitting
antennas. Because such persons will always be in the near field of AM antennas, due to the
relatively long wavelengths in the AM frequency band, an evaluation of both electric and
magnetic field strength is necessary.

In the original version of OET Bulletin 65, staff from the U.S. Environmental
Protection Agency (EPA) provided the FCC with results from a computer-based model to
help determine compliance with MPE limits for AM radio broadcast stations. The EPA
model used the Numeric Electromagnetic Code (NEC) computer program to predict field-
strength levels near AM monopole antennas. In the past several years a PC-based version of
this code, called MININEC, has also become available. The FCC has used MININEC to
expand and refine the predictions for electric and magnetic field-strength presented in the
original version of Bulletin 65. They are included in this supplement in the form of tables
and figures that can be used in evaluating compliance at these stations.

Tables 1-4 may be used to determine the minimum distance from an AM broadcast
antenna to the point where electric and magnetic field strengths are predicted to correspond to
MPE limit values. The tables provide compliance distances from antennas of various electrical
heights transmitting at various frequencies and using various power levels. The distances
specified are the distances from an antenna at which access should be restricted in order to
comply with both the electric and magnetic field-strength MPE limits. For antennas that do
not correspond to the specific conditions given in these tables, interpolation can be used to
arrive at intermediate values, or, alternatively, the greatest distance for the range used for
interpolation could be used.

Since the MPE limits for the two exposure tiers are similar for most AM frequencies,
and because of variability in compliance distances according to electrical height and operating
frequency, one entry is given in each case that applies for both occupational/controlled and
general population/uncontrolled exposures. These numbers represent the minimum worst-case
distances predicted for compliance with the strictest MPE limit for each case. Note that time-

1
averaging considerations are not taken into account in these computations. Continuous
exposure is assumed in all cases.

This model computes field strength values in the vicinity of single antennas. For AM
stations with multiple-tower arrays a conservative "worst case" prediction could be made by
assuming that all transmitted power is radiated from each antenna. Therefore, in such cases
the appropriate value from the tables could be used to define a zone of restriction around the
array, consisting of circles with equal radii, each of which is centered around a tower in the
array. Alternatively, a more accurate prediction could be made if the power actually radiated
by each tower is known.

It may be necessary to predict electric and magnetic field-strength at various locations

in the vicinity of AM antennas. Therefore, Figures 1-4 have been developed for this purpose
using MININEC. These figures show conservative predictions of electric and magnetic field-
strength versus distance from typical AM broadcast antennas for towers with electrical heights
equal to 0.1, 0.25, 0.5, and 0.625 wavelengths, respectively.

Figures 1-4 predict field strength for stations transmitting with 1 kilowatt of power.
Therefore, for stations operating at other power levels values obtained from these figures
should be multiplied by the square root of the station’s power. The following example
illustrates the proper procedure. In this example a 50 kilowatt AM station is located near a
publicly accessible area. It is desired to obtain an estimate of the field-strength levels in this
area which is at a distance of 10 meters from the station’s single tower that has an electrical
height of 0.25. To arrive at the estimated field strength values proceed as follows:

Consult Figure 2 for an antenna with electrical height = 0.25

At 10 meters read predicted electrical field-strength = about 8 V/m

At 10 meters read predicted magnetic field-strength = about 0.06 A/m

Multiply each value by

Predicted values are 56.6 V/m and 0.42 A/m

As discussed in Section 4 of Bulletin 65, RF currents will be induced in the body of

persons who climb transmitting AM broadcast antennas for maintenance or other purposes.
This is a significant source of RF exposure and can be related to the limits for specific
absorption rate (SAR) adopted by the FCC.1 Although many stations may prefer to shutdown
power entirely while persons are climbing their antennas, in some cases this may be difficult
or undesirable. Studies have been undertaken by the FCC and the EPA to determine

1
SAR is discussed in Section 1 of Bulletin 65.

2
appropriate operating power levels which should allow climbing of transmitting AM antennas
without exceeding the SAR guidelines.2 The results of these studies were used to develop
Figure 5, which shows operating power levels versus frequency for a variety of different
electrical heights that are predicted to allow tower climbing without exceeding the exposure
guidelines in terms of SAR. Recommended power levels are shown for tower climbing with
or without the use of gloves. A study by Tell performed for the FCC (Reference 28 in
Bulletin 65) indicated that certain gloves (particularly leather gloves) can significantly reduce
the induction of RF currents in tower climbers.

Figure 5 is designed to be used to provide guidance for use by AM radio stations

which find it necessary to continue transmitting while persons are climbing their towers. It
can be used to determine the levels to which operating power should be reduced before a
person climbs an active tower. However, there is variability in the data, and whenever there
is a question about which condition may apply in a given situation it is recommended that the
most conservative power level be used or, alternatively, that power be turned off completely
while the climber is on the tower.

2
See References 6, 26, 27, 28 and 32 in OET Bulletin 65.

3
TABLE 1. Predicted Distances for Compliance with FCC Limits: O.1 Wavelength

Transmitter Power (kW)

Frequency
(kHz) 50 10 5 1
Predicted Distance for Compliance with FCC Limits (meters)

535-740 13 7 6 3

750-940 12 7 5 3

950-1140 11 6 5 3

1150-1340 10 6 5 3

1350-1540 10 6 5 3

1550-1705 10 6 5 3

TABLE 2. Predicted Distances for Compliance with FCC Limits: O.25 Wavelength

Transmitter Power (kW)

Frequency
(kHz) 50 10 5 1
Predicted Distance for Compliance with FCC Limits (meters)

535-740 4 2 2 1

750-940 4 2 2 1

950-1140 4 2 2 1

1150-1340 4 2 2 1

1350-1540 4 2 2 1

1550-1705 5 2 2 1

4
TABLE 3. Predicted Distances for Compliance with FCC Limits: O.5 Wavelength

Transmitter Power (kW)

Frequency
(kHz) 50 10 5 1
Predicted Distance for Compliance with FCC Limits (meters)

535-740 4 3 2 2

750-940 4 2 2 2

950-1140 4 2 2 1

1150-1340 4 2 2 2

1350-1540 4 2 2 2

1550-1705 4 3 2 1

TABLE 4. Predicted Distances for Compliance with FCC Limits: 0.625 Wavelength

Transmitter Power (kW)

Frequency
(kHz) 50 10 5 1
Predicted Distance for Compliance with FCC Limits (meters)

535-740 4 3 2 1

750-940 4 2 2 1

950-1140 4 2 2 1

1150-1340 4 2 2 1

1350-1540 4 2 2 1

1550-1705 4 2 2 2

5
 1680 2.17
1000
2.00

Electric Field

Total Magnetic Field (A/m)

1.75
Magnetic Field

100 1.50

1.25
Total Electric Field (V/m)

Note: Fields are computed at 2 meters above ground.

10 1.00

0.75

0.50
1

0.25

0.00
0 5 10 15

Distance (Meters)

Figure 1. MININEC AM Model for 1 kW, 0.10 Wavelength Tower

 80 0.7

70
Electric Field 0.6

Total Magnetic Field (A/m)

Magnetic Field
60
Note: Fields are computed at 2 meters above ground. 0.5

50
0.4
Total Electric Field (V/m)

40

0.3
30

0.2
20

0.1
10

0 0.0
0 5 10 15

Distance (Meters)

Figure 2. MININEC AM Model for 1 kW, 0.25 Wavelength Tower

 375 0.18
350 Electric Field 0.17
0.16
325 Magnetic Field

Total Magnetic Field (A/m)

0.15
300
Note: Fields are computed at 2 meters above ground. 0.14
275 0.13
250 0.12
225 0.11
0.10
Total Electric Field (V/m)

200
0.09
175
0.08
150 0.07
125 0.06
100 0.05
0.04
75
0.03
50
0.02
25 0.01
0 0.00
0 5 10 15

Distance (Meters)

Figure 3. MININEC AM Model for 1 kW, 0.5 Wavelength Tower

 375 0.6
350
325
Electric Field 0.5

Total Magnetic Field (A/m)

300
Magnetic Field
275
250 0.4
Note: Fields are computed at 2 meters above ground.
225
Total Electric Field (V/m)

200
0.3
175
150
125 0.2
100
75
0.1
50
25
0 0.0
0 5 10 15

Distance (Meters)

Figure 4. MININEC AM Model for 1 kW, 0.625 Wavelength Tower

 1600
FCC/EPA Study (without gloves)
0.150 wavelength 0.500 wavelength
1400
0.250 wavelength 0.625 wavelength

1200 Tell Study 0.25-0.625 wavelength (without gloves)

Tell Study 0.25-0.625 wavelength (with specific leather gloves)
Projected AM Power Limit (watts)

1000

800

600

400

200

0
540 600 700 800 900 1000 1100 1200 1300 1400 1500 1600
Frequency (kHz)

Figure 5. Estimated power levels to comply with occupational/controlled limits for on-tower exposure of persons climbing AM
broadcast towers (applies only to exposure of persons climbing a transmitting AM radio tower).
 SECTION 2
FM Radio Broadcast Stations

Antennas used for FM radio broadcast stations normally consist of an array of

elements stacked vertically and typically side-mounted on a tower. The elements are usually
spaced about one wavelength apart and are fed in phase with power distributed equally among
the elements. FM radio stations transmit in the 88-108 MHz band. Consulting Table 1 in
Appendix A of OET Bulletin 65 shows that at these frequencies the MPE limit for general
population/uncontrolled exposure is 0.2 mW/cm² (200 µW/cm2) and the limit for
occupational/controlled exposure is 1 mW/cm² (1000 µW/cm2).

Section 2 of Bulletin 65 explains how calculations can be performed to predict RF

field-strength or power density near various antennas, including those used for FM radio
transmissions. In addition, in 1985, the Environmental Protection Agency (EPA) developed a
computer model for estimating ground-level power densities in the vicinity of typical FM
broadcast towers. The EPA model estimates power densities in the vicinity of typical FM
broadcast antennas for various antenna types and patterns. With some minor modifications,
the FCC has successfully used this model over the past several years to predict ground-level
power densities near FM towers. The EPA model considers the following variables of an FM
antenna in arriving at is predictions: (1) the total effective radiated power (both horizontal
and vertical), (2) the height above ground to the center of radiation of the antenna, (3) the
type of antenna element used in the antenna array and (4) the number of elements (or bays) in
the antenna array. The model is discussed in detail in an EPA publication by P. Gailey and
R. Tell (Reference 11 in Bulletin 65). The FCC’s version of the FM computer model can be
downloaded from the FCC’s Office of Engineering and Technology World Wide Web site.3

The FM computer model uses element and array radiation patterns to develop
predicted field strengths and power densities on the ground.4 Ground reflection is taken into
account in these calculations (a factor of 1.6 for field strength as discussed in Section 2 of
Bulletin 65). Although the model is theoretical, measurements made by the EPA and by
others around existing FM antenna towers have shown good agreement with predicted values.

3
The FCC’s FM computer model ("FM Model") may be downloaded via the Internet from the FCC’s
Web Site at http://www.fcc.gov/oet/info/software/. Any future revisions to this software may be found at this
location. For further details contact: rf safety@fcc.gov or the FCC’s RF Safety Program at (202) 418-2464.

4
The EPA measured the vertical radiation patterns of several element types and incorporated the
measurement data into its computer model. The FCC has also used the EPA element pattern data and has added
other data submitted by manufacturers for additional antenna elements.

11
 For a variety of antenna types, the FM computer model has been used by the FCC and
others to predict values of far-field equivalent power density at specific locations on the
ground relative to existing or proposed FM antennas. The model can also be used to predict
the minimum height to an antenna’s center of radiation necessary to prevent RF levels from
exceeding an established level, such as the 200 µW/cm2 MPE limit for general
population/uncontrolled exposure. The FCC version of the FM computer model calculates
fields at a height of 2 meters above ground, taken as the approximate upper range for the
height of a standing person.

In performing any calculations for an FM radio antenna, whether using the equations
of Section 2 of Bulletin 65 or by use of the FM computer model, the value used for ERP
must be the total ERP. This means that in the case of a "circularly-polarized" antenna the
sum of both the horizontal and vertical ERP values must be used. For example, an FM
station using a circularly-polarized antenna that is authorized to use 100 kilowatts (kW) ERP
in the horizontal polarization could be assumed to have a total ERP of 200 kW (100 + 100),
unless otherwise specified.

Using the FM computer model, tables and figures have been derived for use by FM
station licensees and applicants in evaluating compliance with the FCC’s RF exposure limits.
Table 5 lists estimated minimum antenna heights necessary to prevent power densities on the
ground (actually at 2 m above ground) from exceeding the FCC’s occupational/controlled
MPE limits. Table 6 gives estimated antenna heights necessary to prevent "ground-level"
power densities (2 m above ground) from exceeding the general population/uncontrolled MPE
limits. The tables and figures in this section are designed to predict spatial peak values for
power densities rather than values that are spatially-averaged over a given dimension such as
the height of a human being. In that regard, the results may be conservative, and, in some
cases, could indicate non-compliance when, in fact, a station may be in compliance.

Tables 5 and 6 should be consulted as a first step in evaluating an existing or

proposed FM radio broadcast facility to determine whether it would comply with the FCC’s
MPE limits at ground level. Both tables will need to be consulted to ensure that ground-level
exposures for all persons, whether workers or members of the general public, are below the
appropriate acceptable levels. If non-compliance is indicated then some restriction of access
or other mitigating measures may be necessary (see Section 4 of Bulletin 65 on controlling
exposure for more information). In the case of Table 5, if a given tower height is less than
the appropriate minimum value for occupational/controlled exposure, appropriate work
practices may have to be implemented to ensure protection of personnel at the tower site (see
Section 4 of Bulletin 65).

Note that Tables 5 and 6 give predicted minimum heights to the radiation center for a
number of combinations of total ERP and number of elements (bays). Note that for each
entry in the tables two values are given. In each case the top (higher) number represents the
"worst case" where computations were based on using dipole elements in arrays with one-

12
wavelength spacing.5 The bottom (lower) entries in the table represent a typical "best case"
where computations used antenna elements that, according to EPA’s analysis, were designed
to minimize radiation in the direction of the ground.6

It is important to recognize that the values in Tables 5 and 6 apply to single FM

antennas and to towers whose bases are approximately at the same level or higher than the
surrounding terrain. For multiple antennas on the same tower, it would be possible to arrive
at a worst-case estimate using these tables by assuming that the total ERP from all antennas
was concentrated at the radiation center of the antenna that is lowest on the tower. For such
an imaginary radiating source, the number of elements could be considered to be that of the
antenna with the smallest number of elements. A more accurate estimate could be made by
using Figures 6-15 (described below) or by using the FM model software to estimate power
density contributions from each antenna at a ground-level point of interest and then add the
contributions to arrive at the total predicted power density at that point.

In some cases FM radio antennas may have a relatively large number of elements and
the lowest element may be a significant distance from the radiation center. The FM computer
model may not be accurate when predicting field levels from relatively large multiple-element
arrays at distances very close to the antenna. For example, in some cases the minimum
antenna height computed using the FM computer model may be on the order of or less than
one-half the array length (meaning that the antenna would be mounted with its lowest element
at or below ground). Obviously this is not a realistic or desirable situation. Therefore, in
Tables 5 and 6, values have been adjusted to ensure that the lowest element in an array is at
least 3 meters above ground-level in all cases, i.e., head height plus an additional 1-meter
margin of safety. These adjusted numbers are marked with the "*" symbol.7

For FM antennas with ERP/element combinations that are intermediate to the values
listed in Tables 5 and 6, interpolation can be used between table entries, assuming a direct
relation between antenna height and power and an inverse relation between antenna height

5
As shown by the EPA model, the use of dipole elements in an array results in the greatest amount of
downward radiation due to the approximately circular radiation pattern of a dipole.

6
As shown by the EPA and others, other element types generate vertical radiation patterns that tend to
minimize downward radiation significantly. The "best case" element studied by the EPA had a maximum
downward radiation field factor of less than 0.2 compared to the approximate 1.0 maximum for a dipole element.

7
These values were determined by first calculating the longest wavelength that can be utilized for FM
radio broadcast (about 3.4 meters at 88 MHz). Assuming one-wavelength spacing between the elements in an
antenna array, the greatest possible length for an array with a given number of elements can be approximated.
Since the radiation center will be located in the middle of the array, the minimum height of the antenna above
ground has to be at least one-half of the array length. The values for minimum height given in the tables are
always at least 3 meters greater than one-half the calculated array length even though the FM computer model
may indicate a lesser value.

13
and number of elements. Alternatively, the next highest value could be used for ERP and the
next lowest value could be used for number of elements. For example, with respect to the
public/uncontrolled MPE limits, an FM station with a total ERP of 20 kW and 5 elements
could use the values given in Table 6 for 25 kW and 4 bays (51.5 meters, worst case, or 21.1
meters, best case), since these values would be conservative. Interpolation would yield more
realistic values of either 45.4 m or 45.1 m for worst case, depending on whether the 4-bay or
6-bay column is used. Similar interpolation could be performed for the best case values.

In determining compliance for a proposed or existing FM facility, Tables 5 and 6 may

be used initially to determine that a station is or will be in compliance with the MPE limits.
However, if comparison with the appropriate values in the tables indicates potential non-
compliance, i.e., if the antenna center of radiation is less than the indicated minimum tower
height necessary for compliance, further analysis will be necessary. For example, Figures 6-
15 can be consulted, calculations can be made (see Section 2 of Bulletin 65) or FM model
software can be used to determine predicted field levels. Bulletin 65 can then be consulted
for information on how to ensure compliance (e.g., Section 4 on controlling exposure).

Figures 6-15 were generated using the FCC’s FM computer model. These figures
include curves of predicted far-field equivalent, "ground-level" power density (2 m above
ground) versus distance from the base of towers on which FM antennas are mounted for
various combinations of total ERP, height to radiation center and number of elements. By
consulting the appropriate figure, the exposure level at a given point near the ground can be
predicted, thereby determining places where access may have to be restricted. It should be
emphasized that these figures show "worst-case" curves assuming dipole elements in the FM
antenna array. Therefore, the values in these figures should be conservative and should
represent the upper range for power densities for the given conditions. In general, if the FM
computer model is used with other element type different curves, with lower power density
values, would be generated for a given set of conditions.

The following example illustrates how Figures 6-15 could be used to identify the area
around the base of an FM broadcast tower where access may have to be restricted or power
densities may have to be reduced in some way in order to comply with the MPE limits. In
this example it is desired to determine the location where the MPE limit for general
population/uncontrolled exposure of 200 µW/cm2 for the FM radio band would be predicted to
be exceeded. Assume that the station has the following characteristics:

Total ERP = 200 kW (100 kW horizontal + 100 kW vertical polarization)

Height above ground to radiation center = 82 meters
Number of elements = 4
Spacing between elements in the antenna array = 1.0

The height of the radiation center in this example is 82 meters, which can be rounded
to 80 meters for purposes of using the appropriate figure (Figure 13). It is necessary to round

14
down instead of up so that the power density will not be underestimated. Figures 6-15 are
normalized for 1 kW of total ERP, i.e., power density values are in terms of power density
per kilowatt ERP, so the power density values given in the figure will have to be converted
to account for the higher power level of the example station. The following procedure should
be used to obtain the desired information.

Divide the MPE limit of 200 µW/cm2 by the total station ERP of
200 kW to obtain 1 µW/cm2/kW (power density per kW)

Find 1 µW/cm2/kW on the vertical axis of Figure 13 (for 80 m

antenna height)

Find the point on the 4-element curve corresponding to 1

µW/cm2/kW and locate the predicted distance (about 48 m) on the
horizontal axis

The result of this analysis means that a fence or other appropriate restrictive barrier
could be placed at this distance to prevent access to the tower site where levels are predicted
to exceed the MPE limits for the general public. This would be a means to comply with the
general population/uncontrolled MPE limits. Section 4 of Bulletin 65 provides further
discussion on controlling exposure.

Figures 6-15 can be used to predict exposure to any power density level by using the
above-described approach. For example, to find the minimum distance to 1000 µW/cm2 (the
occupational/controlled exposure limit for the FM band), simply divide 1000 (rather than 200
in the above example) by the total ERP and proceed as above. In that case, the resulting
value of 5 µW/cm2/kW would imply that the 1000 µW/cm2 limit would not be exceeded
anywhere near the ground for these conditions, since all the numerical values on the curve lie
below this threshold.

It is important to re-emphasize that the predicted values shown in Figures 6 - 15 are

worst case estimates (dipole elements) that represent the maximum predicted levels possible
for any FM antenna using conventional element arrays. Therefore, they are primarily useful
as a conservative approximation that may serve to eliminate the need for further analysis in
many cases. It is very likely that use of most modern, commercially-available FM antennas
will result in actual ground-level power densities that are significantly lower than the values
shown by the curves in these figures. More accurate predictions can be made for these
antennas by using the FM computer model and specifying an element type appropriate to the
antenna system used.

15
 For instances in which an FM antenna is mounted on a building or when the exposure
location being analyzed is not on the ground, Tables 5 and 6 may not apply. For example, to
determine exposure in or on a nearby building or other structure that may be in the direct
line-of-sight of an FM antenna, field strength or power density in the main-beam of the
antenna is more relevant for analytical purposes, and Figures 1 and 2 in Section 2 of Bulletin
65 should be consulted. However, if the location of concern is the rooftop itself, where an
antenna is mounted above the rooftop, then the minimum antenna heights in Tables 5 and 6
could be used as if the rooftop represented the ground.

16
 Total Number of Bays
H+V
ERP 2 4 6 8 10 12
(kW) Meters from Center of Radiation

0.5 5.2 8.1* 11.5* 14.9* 18.3* 21.7*

4.7* 8.1* 11.5* 14.9* 18.3* 21.7*
3 9.7 9.7 11.5* 14.9* 18.3* 21.7*
5.7 8.1* 11.5* 14.9* 18.3* 21.7*
10 16.2 16.0 15.9 15.8 18.3* 21.7*
8.6 8.1* 11.5* 14.9* 18.3* 21.7*
25 24.3 24.2 24.0 23.7 23.5 23.3
12.5 9.8 11.5* 14.9* 18.3* 21.7*
50 33.6 33.3 33.1 32.7 32.4 32.1
16.8 13.1 11.3 14.9* 18.3* 21.7*
75 40.7 40.3 40 39.6 39.2 38.9
20.1 15.6 13.3 14.9* 18.3* 21.7*
100 46.6 46.3 45.9 45.4 45.0 44.6
22.9 17.7 15.1 13.7 18.3* 21.7*
125 51.9 51.5 51.1 50.6 50.0 49.6
25.4 19.6 16.6 15.1 18.3* 21.7*
150 56.7 56.2 55.8 55.2 54.6 54.1
27.6 21.2 18.0 16.4 18.3* 21.7*
175 61.1 60.5 60.1 59.5 58.8 58.3
29.7 22.7 19.3 17.5 16.3 21.7*
200 65.1 64.6 64.1 63.4 62.7 62.2
31.6 24.2 20.5 18.6 17.2 21.7*

Table 5 . Minimum height for single FM antenna compliance with occupational/controlled

exposure limits. The above numbers apply to single FM antennas for which the base of the
supporting tower is at approximately the same level or higher than the surrounding terrain.
For each entry, the higher number represents a "worst case" assuming a dipole-type element
in the antenna array. The lower number for each entry represents a typical "best case"
achievable using modern, commercially-available antennas. For intermediate combinations of
power or number of elements interpolation is acceptable, as explained in the text. See text
for explanation of entries with "*" symbol.

17
 Total Number of Bays
H+V
ERP 2 4 6 8 10 12
(kW) Meters from Center of Radiation

0.5 9.1 9.0 11.5* 14.9* 18.3* 21.7*

5.3 8.1* 11.5* 14.9* 18.3* 21.7*
3 19.3 19.2 19.0 18.8 18.7 21.7*
10.1 8.1 11.5* 14.9* 18.3* 21.7*
10 33.6 33.3 33.1 32.7 32.4 32.1
16.8 13.1 11.3 14.9* 18.3* 21.7*
25 51.9 51.5 51.1 50.6 50.0 49.6
25.4 19.6 16.6 15.1 18.3* 21.7*
50 72.6 71.9 71.4 70.7 69.9 69.3
35.1 26.8 22.7 20.6 19.1 17.6
75 88.4 87.7 87.0 86.1 85.1 84.4
42.6 32.5 27.3 24.8 22.9 21.2
100 101.8 100.9 100.1 99.1 98.0 97.1
48.8 37.1 31.2 28.3 26.2 24.1
125 113.6 112.6 111.7 110.5 109.3 108.4
54.6 41.2 34.6 31.4 29.0 26.7
150 124.2 123.1 122.2 120.9 119.6 118.5
59.6 45.0 37.9 34.2 31.6 29.1
175 133.4 132.8 131.8 130.4 129.0 127.9
64.0 48.3 40.6 36.7 33.9 31.2
200 143.1 141.8 140.8 139.3 137.7 136.5
68.0 51.7 43.3 39.1 36.1 33.2

Table 6. Minimum height for single FM antenna compliance with general

population/uncontrolled exposure limits. The above numbers apply to single FM antennas for
which the base of the supporting tower is at approximately the same level or higher than the
surrounding terrain. For each entry, the higher number represents a "worst case" assuming a
dipole-type element in the antenna array. The lower number for each entry represents a
typical "best case" achievable using modern, commercially-available antennas. For
intermediate combinations of power or number of elements interpolation is acceptable, as
explained in the text. See text for explanation of entries with "*" symbol.

18
 Radiation Center Above Ground = 10 meters

1000 1000

Normalized Power Density (µW/cm²)/kW

100 100

2 Elem
4 Elem

ents
ents
10 10

1 1

0.1 0.1
1 10 100 200
Distance from Tower (meters)

Figure 6. Predicted "worst case" power density (@ 2 m above ground) for 10 m antenna height.
 Radiation Center Above Ground = 20 meters

Normalized Power Density (µW/cm²)/kW 100 100

6 Elem

4 Elem
8 Elem ts
10 Ele

2 Elem
10 10

men

ents

ents
ents

ents
1 1

0.1 0.1

0.01 0.01
1 10 100 200
Distance from Tower (meters)

Figure 7. Predicted "worst case" power density (@ 2 m above ground) for 20 m antenna height.
 Radiation Center Above Ground = 30 meters

Normalized Power Density (µW/cm²)/kW 100 100

10 10

12 Ele
10 Elements
8 Elem t s
6 Elem

2 Elem
4 Elem
men
ents
ents

ents
ents
1 1

0.1 0.1

0.01 0.01
1 10 100 200
Distance from Tower (meters)

Figure 8. Predicted "worst case" power density (@ 2 m above ground) for 30 m antenna height.
 Radiation Center Above Ground = 40 meters

Normalized Power Density (µW/cm²)/kW 100 100

10 10

10 Ele ents

2 Elem
4 Elem
6 Elem
8 Elem
12 Ele
ments
m

ents
ents
ents
ents
1 1

0.1 0.1

0.01 0.01
1 10 100 200
Distance from Tower (meters)

Figure 9. Predicted "worst case" power density (@ 2 m above ground) for 40 m antenna height.
 Radiation Center Above Ground = 50 meters

10 10
Normalized Power Density (µW/cm²)/kW

12 Elem
10 Elements
8 Eleme nts
6 Eleme

4 Elem

2 Elem
ents

ents
e
nts
nts
1 1

0.1 0.1

0.01 0.01
1 10 100 200
Distance from Tower (meters)

Figure 10. Predicted "worst case" power density (@ 2 m above ground) for 50 m antenna height.
 Radiation Center Above Ground = 60 meters

Normalized Power Density (µW/cm²)/kW 10 10

12 Ele
10 Ele ents

2 Elem
6 Elem

4 Elem
8 Elem n t s
1 1

m
me

ents
ents

ents
ents
0.1 0.1

0.01 0.01
1 10 100 200
Distance from Tower (meters)

Figure 11. Predicted "worst case" power density (@ 2 m above ground) for 60 m antenna height.
 Radiation Center Above Ground = 70 meters

Normalized Power Density (µW/cm²)/kW 10 10

10 Ele ents

6 Elem
8 Elem
12 Ele

4 Elem
1 1

2 Elem
ments
m

ents
ents

ents

ents
0.1 0.1

0.01 0.01
1 10 100 200
Distance from Tower (meters)

Figure 12. Predicted "worst case" power density (@ 2 m above ground) for 70 m antenna height.
 Radiation Center Above Ground = 80 meters

Normalized Power Density (µW/cm²)/kW 10 10

1 1

6 Ele

4 Ele
10 Ellements
8 Ele ents
12 E

2 Ele
ment

ment
ment
em

ment
s

s
s

s
0.1 0.1

0.01 0.01
1 10 100 200
Distance from Tower (meters)

Figure 13. Predicted "worst case" power density (@ 2 m above ground) for 80 m antenna height.
 Radiation Center Above Ground = 90 meters
Normalized Power Density (µW/cm²)/kW 10 10

2 Ele
4 Ele
6 Ele
10 E lements
8 Ele ments
12 E
1 1

men
men
le

men
men

ts
ts
ts
ts
0.1 0.1

0.01 0.01
1 10 100 200
Distance from Tower (meters)

Figure 14. Predicted "worst case" power density (@ 2 m above ground) for 90 m antenna height.
 Radiation Center Above Ground = 100 meters

10 10
Normalized Power Density (µW/cm²)/kW

1 1

2 Eleme
4 Eleme
6 Eleme
10 Elem nts
8 Eleme
12 Elem

nts
nts
nts
nts
ents
e
0.1 0.1

0.01 0.01
1 10 100 200
Distance from Tower (meters)

Figure 15. Predicted "worst case" power density (@ 2 m above ground) for 100 m antenna height.
 SECTION 3
Television Broadcast Stations

Antennas used for television broadcasting usually consist of an array of radiating

elements mounted on a tower. In comparison to elements used for FM antennas, the elements
used for television broadcasting are generally of a more complex design and radiate less
energy downward than many FM antennas. Television broadcast antennas are also often
mounted on higher towers than those used for FM radio broadcasting.

The computer model developed by the EPA for FM radio broadcast antennas,
discussed previously, was not applied to television broadcast antennas due to the
unavailability of complete vertical radiation patterns for these antennas. However, the EPA
did develop an alternative approach for analyzing television antenna systems based on
available information. It should be noted that this model will have to be modified in the
future if it is to be applied to digital television systems expected to be developed over the
next several years.

For VHF-TV antennas, the EPA reported that the most commonly used type of
radiating element appeared to be the "bat wing" type. For purposes of preliminary evaluation
it can be assumed that all VHF-TV elements are of this design. Data obtained by EPA
indicated that antennas using batwing elements may radiate approximately 20% as much in
the downward direction as in the main beam in terms of relative field strength. Therefore, the
relative field factor, F (discussed in Section 2 of Bulletin 65), in the downward direction
could be assumed to be on the order of 0.2.8

Although detailed modeling was not performed, the EPA used typical values of
relative field strength directly beneath the antenna, i.e., the shortest distance to ground, to
arrive at its prediction model for ground-level fields due to VHF-TV antenna systems. For
directions other than straight down, greater distances from the antenna would be involved,

8
The use of a relative field factor (F) allows a more accurate prediction for power density. If the relative
field factor is not known, a value of 1.0 could be assumed for a very conservative, worst-case approximation.
The 20% level assumed by EPA for VHF-TV antennas in the downward direction is an average value and would
not necessarily apply in all cases. However, a value of 1.0 in the downward direction is unlikely for TV
antennas. A 1.0 value for the field factor is more appropriate for evaluating main-beam exposure.

29
resulting in lower predicted fields at ground level. The EPA developed the following general
equation to predict fields at the base of television broadcast towers.

(1)

where:
S = power density in microwatts/sq. cm (µW/cm2)
F = relative field factor in the downward direction of interest (-60˚ to -90˚ elevation)
ERPV = total peak visual ERP in watts9
ERPA = total aural ERP in watts
R = distance from ground (or @ 2m above ground) to center of radiation in meters

In Equation (1) the value of 2.56 is the ground-reflection factor discussed in Section 2
of Bulletin 65. The value of 1.64 is the gain of a half-wave dipole relative to an isotropic
radiator, also as discussed in Section 2. The factor of 0.4 converts peak visual ERP to an
RMS value which is more realistic with regard to practical conditions of video transmission.
The factor of 100 in the equation is a conversion factor. For convenience Equation (1) can be
simplified to the following expression (same units as above):

(2)

If the relative field factors, F, (derived from the relative power gain) are known from
an antenna’s vertical radiation pattern, Equations (1) and (2) can be used to arrive at
predictions of ground-level power density that are much more accurate than would be the case
by using a worst-case estimate of 1.0 for F. For VHF-TV antennas the value of 0.2 for F can
generally be assumed. However, it should be kept in mind that this value generally represents
an average and may not necessarily apply in all cases and in all directions.

The following equation, Equation (3), derived from Equations (1) and (2) can be used
to predict the minimum antenna height necessary to bring a television station below a given
power density level anywhere on the ground:

9
The values for ERP in this equation are total ERP. Therefore, although most television antennas transmit
in the horizontal polarization, if a circularly-polarized antenna should be used the contributions from both
horizontal and vertical polarizations must be included.

30
 (3)

where: MAH = minimum antenna height (ground to center of radiation) necessary to

reduce ground-level RF fields below a given power density, S, (units same
as Equation 1).

Equations (1) - (3) can be used for both VHF and UHF television antennas. However,
for UHF antennas, the EPA model used different typical values of F, the relative field factor
in the downward direction. It is reasonable to expect generally smaller F values for UHF
antennas than from VHF antennas. UHF antennas have very high gain in the main beam
which means that a higher proportion of the transmitted energy is concentrated there rather
than radiated downward or in other directions. Although EPA was not able to obtain relative
field data from antenna manufacturers’ literature, an alternative prediction method was
developed based on field data and discussions with one major manufacturer. The
manufacturer’s engineers stated that typical values of F for UHF antennas are about 10%, and
some more expensive antennas have an F of about 5% for downward radiation. These values
agreed well with measurements made by the EPA in field studies beneath UHF antennas.

Equation (3) was used to prepare Tables 7 - 12 in this section. These tables show
minimum "worst case" distances from single VHF or UHF television antennas required for
compliance with the FCC’s MPE limits.10 Individual tables specify various combinations of
visual and aural power and show distances for compliance with either general
population/uncontrolled limits or occupational/controlled limits, with or without the
assumption of surface reflection.11 For intermediate values of visual or aural power an
applicant may interpolate between values given in the tables, or, alternatively, use the value
given for the next highest level of visual and/or aural power. As indicated previously, total
ERP must be used.

When F, the relative field factor, is known, Equation (3) above can be used to
calculate minimum antenna height for compliance with a specified limit. However, if F is not
known, the values given in these tables can be used (which assume a value of 1.0 for F) as a
worst-case estimate for ground-level exposure. However, these values will be very

10
Note that for VHF-TV frequencies the MPE limits are 200 µW/cm2 (general population/uncontrolled) and
1000 µW/cm2 (occupational/controlled). For UHF-TV frequencies the MPE limits vary with frequency (see
Appendix A to Bulletin 65 for details).
11
Surface reflection will result in higher predicted values (see Section 2 of Bulletin 65).

31
conservative, as discussed previously. Tables using field factors less than 1.0, such as 0.2 or
0.1, could also be constructed and may be included in future revisions of this supplement.

Using Tables 7 - 12 for estimating minimum antenna height can be useful in cases
where the supporting tower is relatively short and there may be a greater contribution to
ground-level field strength from the lower part of the antenna. For main-beam exposure,
where the field factor, F, may be closer to 1.0, the values in these tables are likely to be
provide more realistic predictions of exposure at a given distance. This type of analysis may
be required when nearby occupied structures or rooftops are in the path of the antenna’s main
beam. In such cases it may or may not be reasonable to include the surface reflection factor
in equation (3). For that reason the values in tables labeled "No Reflection" were calculated
without the reflection factor of 2.56 shown in Equation (1) and included in Equation (3).

32
Table 7. Distances for Single VHF-TV Antenna Compliance with FCC-Limits (see text)
(relative field factor = 1, assumes no surface reflection)
Max. Aural Power (% of Max. Visual Power)
Visual
ERP 5 10 12.5 15 20 22
(kW)
Meters from Center of Radiation (m)

5 12.1 12.8 13.1 13.4 14.0 14.2

5.4 5.7 5.9 6.0 6.3 6.4

25 27.1 28.6 29.3 30.0 31.3 31.8

12.1 12.8 13.1 13.4 14.0 14.2

50 38.3 40.4 41.4 42.4 44.2 45.0

17.1 18.1 18.5 18.9 19.8 20.1

75 46.9 49.5 50.7 51.9 54.2 55.1

21.0 22.1 22.7 23.2 24.2 24.6

100 54.2 57.1 58.5 59.9 62.6 63.6

24.2 25.5 26.2 26.8 28.0 28.4

125 60.6 63.9 65.4 67.0 70.0 71.1

27.1 28.6 29.3 30.0 31.3 31.8

150 66.4 70.0 71.7 73.4 76.6 77.9

29.7 31.3 32.1 32.8 34.3 34.8

175 71.7 75.6 77.4 79.3 82.8 84.1

32.1 33.8 34.6 35.4 37.0 37.6

200 76.6 80.8 82.8 84.7 88.5 90.0

34.3 36.1 37.0 37.9 39.6 40.2

225 81.3 85.7 87.8 89.9 93.9 95.4

36.4 38.3 39.3 40.2 42.0 42.7

250 85.7 90.3 92.5 94.7 98.9 100.6

38.3 40.4 41.4 42.4 44.2 45.0

275 89.9 94.7 97.1 99.3 103.8 105.5

40.2 42.4 43.4 44.4 46.4 47.2

300 93.9 98.9 101.4 103.8 108.4 110.2

42.0 44.2 45.3 46.4 48.5 49.3

316 96.3 101.5 104.0 106.5 111.2 113.1

43.1 45.4 46.5 47.6 49.7 50.6
NOTES:
1. The top number indicates the height requirement for compliance with general population/uncontrolled limits.
The bottom number indicates the height required for compliance with occupational/controlled limits.
2. For intermediate values interpolate between tabulated numbers or use equation (3)
3. The above values assume total visual ERP. Transmitting facilities using circularly polarized antennas must
include sum of ERP in both horizontal and vertical polarizations.

33
Table 8. Distances for Single VHF-TV Antenna Compliance with FCC-Limits (see text)
(relative field factor = 1, assumes surface reflection)
Max. Aural Power (% of Max. Visual Power)
Visual
ERP 5 10 12.5 15 20 22
(kW)
Meters from Center of Radiation (m)

5 19.4 20.4 20.9 21.4 22.4 22.8

8.7 9.1 9.4 9.6 10.0 10.2

25 43.4 45.7 46.8 47.9 50.1 50.9

19.4 20.4 20.9 21.4 22.4 22.8

50 61.3 64.6 66.2 67.8 70.8 72.0

27.4 28.9 29.6 30.3 31.7 32.2

75 75.1 79.1 81.1 83.0 86.7 88.1

33.6 35.4 36.3 37.1 38.8 39.4

100 86.7 91.4 93.6 95.9 100.1 101.8

38.8 40.9 41.9 42.9 44.8 45.5

125 96.9 102.2 104.7 107.2 111.9 113.8

43.4 45.7 46.8 47.9 50.1 50.9

150 106.2 111.9 114.7 117.4 122.6 124.6

47.5 50.1 51.3 52.5 54.8 55.7

175 114.7 120.9 123.9 126.8 132.4 134.6

51.3 54.1 55.4 56.7 59.2 60.2

200 122.6 129.2 132.4 135.6 141.6 143.9

54.8 57.8 59.2 60.6 63.3 64.4

225 130.1 137.1 140.5 143.8 150.2 152.7

58.2 61.3 62.8 64.3 67.2 68.3

250 137.1 144.5 148.4 151.9 158.6 161.2

61.3 64.6 66.2 67.8 70.8 72.0

275 143.8 151.6 155.3 159.0 166.0 168.8

64.3 67.8 69.5 71.1 74.2 75.5

300 150.2 158.3 162.2 166.0 173.4 176.3

67.2 70.8 72.5 74.2 77.5 78.8

316 154.1 162.5 166.5 170.4 178.0 180.9

68.9 72.7 74.4 76.2 79.6 80.9
NOTES:
1. The top number indicates the height requirement for compliance with general population/uncontrolled limits.
The bottom number indicates the height required for compliance with occupational/controlled limits.
2. For intermediate values interpolate between tabulated numbers or use equation (3).
3. The above values assume total visual ERP. Transmitting facilities using circularly polarized antennas must
include sum of ERP in both horizontal and vertical polarizations.

34
Table 9. Distances for Single UHF-TV Antenna Compliance with FCC-Limits (see text)
(aural power = 10% VERP; relative field factor = 1; assumes surface reflection)
Peak Visual ERP (kW)
Channel
Range 250 500 1000 2000 3000 4000 5000

Meters from Center of Radiation (m)

14 - 17 115.5 163.3 230.9 326.5 399.9 461.8 516.3

51.6 73.0 103.3 146.0 178.9 206.5 230.9

18 - 21 112.6 159.3 225.2 318.5 390.1 450.4 503.6

50.3 71.2 100.7 142.4 174.5 201.4 225.2

22 - 25 110.0 155.5 219.9 311.0 381.0 439.9 491.8

49.2 69.6 98.4 139.1 170.4 196.7 219.9

26 - 29 107.5 152.0 215.0 304.1 372.4 430.0 480.8

48.1 68.0 96.2 136.0 166.6 192.3 215.0

30 - 33 103.0 145.7 206.1 291.5 357.0 412.2 460.8

47.1 66.5 94.1 133.1 163.0 188.2 210.4

34 - 37 103.0 145.7 206.1 291.5 357.0 412.2 460.8

46.1 65.2 92.2 130.3 159.6 184.3 206.1

38 - 41 101.0 142.9 202.0 285.7 349.9 404.0 451.7

45.2 63.9 90.3 127.8 156.5 180.7 202.0

42 - 45 99.1 140.1 198.2 280.3 343.3 396.4 443.1

44.3 62.7 88.6 125.3 153.5 177.3 198.2

46 - 49 97.3 137.6 194.6 275.1 337.0 389.1 435.0

43.5 61.5 87.0 123.1 150.7 174.0 194.6

50 - 53 95.6 135.1 191.1 270.3 331.0 382.2 427.4

42.7 60.4 85.5 121.4 148.0 170.9 191.1

54 - 57 93.9 132.8 187.9 265.7 325.4 375.7 420.1

42.0 59.4 84.0 120.9 145.5 168.0 187.9

58 - 61 92.4 130.7 184.8 261.3 320.0 369.5 413.2

41.3 58.4 82.6 118.8 143.1 165.3 184.8

62 - 65 90.9 128.6 181.8 257.1 314.9 363.6 406.6

40.7 57.5 81.3 116.9 140.8 162.6 181.8

66 - 69 89.5 126.6 179.0 253.2 310.1 358.0 400.3

40.0 56.6 80.1 115.0 138.7 160.1 179.0
NOTES:
1. The top number indicates the height requirement for compliance with general population/uncontrolled limits.
The bottom number indicates the height required for compliance with occupational/controlled limits.
2. For intermediate values interpolate between tabulated numbers or use equation (3).
3. The above values assume total visual ERP. Transmitting facilities using circularly polarized antennas must
include sum of ERP in both horizontal and vertical polarizations.

35
Table 10. Distances for Single UHF-TV Antenna Compliance with FCC-Limits (see text)
(aural Power = 10% VERP, relative field factor = 1, assumes no surface reflection)
Peak Visual ERP (kW)
Channel
Range 250 500 1000 2000 3000 4000 5000

Meters from Center of Radiation (m)

14 - 17 72.2 102.0 144.3 204.1 250.0 288.6 322.7

32.3 45.6 64.5 91.3 111.8 129.1 144.3

18 - 21 70.4 99.5 140.8 199.1 243.8 281.5 314.8

31.5 44.5 63.0 89.0 109.0 125.9 140.8

22 - 25 68.7 97.2 137.5 194.4 238.1 274.9 307.4

30.7 43.5 61.5 86.9 106.5 123.0 137.5

26 - 29 67.2 95.0 134.4 190.1 232.8 268.8 300.5

30.1 42.5 60.1 85.0 104.1 120.2 134.4

30 - 33 65.8 93.0 131.5 186.0 227.8 263.0 294.1

29.4 41.6 58.8 83.2 101.9 117.6 131.5

34 - 37 64.4 91.1 128.8 182.2 223.1 257.6 288.0

28.8 40.7 57.6 81.5 99.8 115.2 128.8

38 - 41 63.1 89.3 126.3 178.6 218.7 252.5 282.3

28.2 39.9 56.5 79.9 97.8 112.9 126.3

42 - 45 61.9 87.6 123.9 175.2 214.5 247.7 277.0

27.7 39.2 55.4 78.3 95.9 110.8 123.9

46 - 49 60.8 86.0 121.6 172.0 210.6 243.2 271.9

27.2 38.5 54.4 76.9 94.2 108.8 121.6

50 - 53 59.7 84.5 119.5 168.9 206.9 238.9 267.1

26.7 37.8 53.4 75.6 92.5 106.8 119.5

54 - 57 58.7 83.0 117.4 166.1 203.4 234.8 262.5

26.3 37.1 52.5 74.3 91.0 105.0 117.4

58 - 61 57.7 81.7 115.5 163.3 200.0 231.0 258.2

25.8 36.5 51.6 73.0 89.5 103.3 115.5

62 - 65 56.8 80.4 113.6 160.7 196.8 227.3 254.1

25.4 35.9 50.8 71.9 88.0 101.6 113.6

66 - 69 56.8 80.4 113.6 160.7 196.8 227.3 254.1

25.0 35.4 50.0 70.8 86.7 100.1 111.9
NOTES:
1. The top number indicates the height requirement for compliance with general population/uncontrolled limits.
The bottom number indicates the height required for compliance with occupational/controlled limits.
2. For intermediate values interpolate between tabulated numbers or use equation (3).
3. The above values assume total visual ERP. Transmitting facilities using circularly polarized antennas must
include sum of ERP in both horizontal and vertical polarizations.

36
Table 11. Distances for Single UHF-TV Antenna Compliance with FCC-Limits (see text)
(aural power = 22% VERP, relative field factor = 1, assumes surface reflection)
Channel Peak Visual ERP (kW)
Range
250 500 1000 2000 3000 4000 5000

Meters from Center of Radiation (m)

14 - 17 128.6 181.8 257.1 363.6 445.3 514.2 574.9

57.5 81.3 115.0 162.6 199.2 230.0 257.1

18 - 21 125.4 177.3 250.8 354.7 434.4 501.6 560.8

56.1 79.3 112.2 158.6 194.3 224.3 250.8

22 - 25 122.5 173.2 244.9 346.4 424.2 489.8 547.6

54.8 77.5 109.5 154.9 189.7 219.1 244.9

26 - 29 119.7 169.3 239.4 338.6 414.7 478.9 535.4

53.5 75.7 107.1 151.4 185.5 214.2 239.4

30 - 33 117.2 165.7 234.3 331.4 405.8 468.6 523.9

52.4 74.1 104.8 148.2 181.5 209.6 234.3

34 - 37 112.5 159.1 225.0 318.1 389.6 449.9 503.0

51.3 72.6 102.6 145.1 177.8 205.3 229.5

38 - 41 112.5 159.1 225.0 318.1 389.6 449.9 503.0

50.3 71.1 100.6 142.3 174.3 201.2 225.0

42 - 45 110.3 156.1 220.7 312.1 382.2 441.4 493.5

49.4 69.8 98.7 139.6 170.9 197.4 220.7

46 - 49 108.3 153.2 216.7 306.4 375.2 433.3 484.4

48.4 68.5 96.9 137.0 167.8 193.8 216.7

50 - 53 106.4 150.5 212.8 301.0 368.6 425.6 475.9

47.6 67.3 95.2 134.6 164.9 190.4 212.8

54 - 57 104.6 147.9 209.2 295.9 362.3 418.4 467.8

46.8 66.2 93.6 132.3 162.0 187.1 209.2

58 - 61 102.9 145.5 205.8 291.0 356.4 411.5 460.1

46.0 65.1 92.0 130.1 159.4 184.0 205.8

62 - 65 101.2 143.2 202.5 286.3 350.7 404.9 452.7

45.3 64.0 90.5 128.1 156.8 181.1 202.5

66 - 69 99.7 141.0 199.3 281.9 345.3 398.7 445.7

44.6 63.0 89.1 126.1 154.4 178.3 199.3
NOTES:
1. The top number indicates the height requirement for compliance with general population/uncontrolled limits.
The bottom number indicates the height required for compliance with occupational/controlled limits.
2. For intermediate values interpolate between tabulated numbers or use equation (3).
3. The above values assume total visual ERP. Transmitting facilities using circularly polarized antennas must
include sum of ERP in both horizontal and vertical polarizations.

37
Table 12. Distances for Single UHF-TV Antenna Compliance with FCC-Limits (see text)
(aural power = 22% VERP, relative field factor = 1, assumes no surface reflection)
Peak Visual ERP (kW)
Channel
Range 250 500 1000 2000 3000 4000 5000

Meters from Center of Radiation (m)

14 - 17 80.4 113.6 160.7 227.3 278.3 321.4 359.3

35.9 50.8 71.9 101.6 124.5 143.7 160.7

18 - 21 78.4 110.8 156.8 221.7 271.5 313.5 350.5

35.1 49.6 70.1 99.1 121.4 140.2 156.8

22 - 25 76.5 108.2 153.1 216.5 265.1 306.1 342.3

34.2 48.4 68.5 96.8 118.6 136.9 153.1

26 - 29 74.8 105.8 149.6 211.6 259.2 299.3 334.6

33.5 47.3 66.9 94.6 115.9 133.9 149.6

30 - 33 73.2 103.6 146.4 207.1 253.6 292.9 327.4

32.7 46.3 65.5 92.6 113.4 131.0 146.4

34 - 37 71.7 101.4 143.4 202.8 248.4 286.9 320.7

32.1 45.4 64.1 90.7 111.1 128.3 143.4

38 - 41 70.3 99.4 140.6 198.8 243.5 281.2 314.4

31.4 44.5 62.9 88.9 108.9 125.8 140.6

42 - 45 69.0 97.5 137.9 195.1 238.9 275.9 308.4

30.8 42.8 60.6 85.6 104.9 123.3 137.9

46 - 49 67.7 95.7 135.5 191.5 234.5 270.8 302.8

30.3 42.8 60.6 85.6 104.9 121.1 135.4

50 - 53 66.5 94.1 133.0 188.1 230.4 266.0 297.4

29.7 42.1 59.5 84.1 103.0 119.0 133.0

54 - 57 65.4 92.5 130.8 184.9 226.5 261.5 292.4

29.2 41.4 58.5 82.7 101.3 116.9 130.8

58 - 61 64.3 90.9 128.6 181.9 222.7 257.2 287.5

28.8 40.7 57.5 81.3 99.6 115.0 128.6

62 - 65 63.3 89.5 126.5 179.0 219.2 253.1 283.0

28.3 40.0 56.6 80.0 98.0 113.2 126.5

66 - 69 62.3 88.1 124.6 176.2 215.8 249.2 278.6

27.9 39.4 55.7 78.8 96.5 111.4 124.6
NOTES:
1. The top number indicates the height requirement for compliance with general population/uncontrolled limits.
The bottom number indicates the height required for compliance with occupational/controlled limits.
2. For intermediate values interpolate between tabulated numbers or use equation (3).
3. The above values assume total visual ERP. Transmitting facilities using circularly polarized antennas must
include sum of ERP in both horizontal and vertical polarizations.

38